On December 24, 2025, the Basic Tax of 5 provinces of Vinh Long received Official Dispatch 02/CV of Ut Hang Seafood Co., Ltd., according to the content presented in the official dispatch, the Basic Tax of 5 provinces of Vinh Long has the following opinions:
Based on Clause 1, Article 9 of Decree 320/2025/ND-CP detailing a number of articles and measures to organize and guide the implementation of the Enterprise Income Tax Law:
Article 9. Deductible expenses when determining taxable income
1. Except for non-deductible expenses specified in Article 10 of this Decree, enterprises are entitled to deduct expenses when determining taxable income if they meet the conditions in points a, b and c below:
a) The actual expenditure incurred related to the production and business activities of the enterprise, including additional expenses deducted as a percentage calculated on the actual expenditure incurred during the tax period related to the enterprise's research and development activities;
...
b) Expenses with sufficient invoices and documents as prescribed by law.
For cases: Buying products that are agricultural, forestry, and aquatic products of producers, directly sold by fishermen; buying handicrafts made of wool, sedge, bamboo, rosewood, leaves, bamboo, rattan, straw, straw, coconut shell, coconut shell or raw materials utilized from agricultural products of directly sold handicraft producers; buying scrap from people directly collecting; buying household goods and assets of households and individuals directly sold; buying goods and services of individuals and business households (excluding the cases mentioned above) with revenue below the value-added tax revenue threshold must have payment documents according to the provisions of law on accounting, invoices, documents for sellers (for cases where the purchase value of goods and services in a day of each household or individual is from 05 million VND or more must be paid without cash) and the Purchase List of goods and services signed and responsible for by a legal representative or authorized person of the enterprise;
c) Expenditures with non-cash payment vouchers for purchases of goods, services and other payments each time with a value of 05 million VND or more. Non-cash payment vouchers are made in accordance with the provisions of legal documents on value-added tax".
Based on the above regulations:
(1) Companies that purchase goods (agricultural products, crops, livestock products...) from people directly producing and selling them, if there are no invoices, must have payment documents for sellers in accordance with the provisions of law on accounting, invoices, documents and sales receipts of goods and services signed and responsible for by legal representatives or authorized persons of enterprises (note: for cases where the purchase value of goods and services in a day of each household or individual is from 05 million VND or more, it is mandatory to pay in cash) then it will be included in reasonable expenses when calculating corporate income tax.
(2) Companies paying employees of enterprises salaries from 05 million VND or more each time without non-cash payment vouchers as prescribed are not included in the deductible expenses when determining corporate income taxable income.
